MOHAWK TANNERYNASHUA, NH

Cleanup Activities

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Background

The former Mohawk Tannery facility (a.k.a. Granite State Leathers) is located on approximately 30 acres in Nashua, Hillsborough County, New Hampshire. The currently inactive facility produced tanned hides for leather between 1924 and 1984. The site was proposed to the National Priorities List (NPL) on the basis of past disposal practices which included the direct discharge of wastewater containing such hazardous substances as chromium, zinc, and phenol into the Nashua River and the disposal of sludge containing such hazardous substances as chromium, pentachlorophenol, phenol, and 2,4,6-trichloropehenol into a number of unlined disposal areas at the site. Two of the largest disposal areas are located directly next to the Nashua River; with one of these areas within the 100-year flood plain. These disposal areas were not designed, constructed, operated, and maintained to prevent the washout of hazardous substances in the event of a flood. The confluence of the Nashua and the Merrimack Rivers is located approximately 3.5 miles downstream of the site. Both the Nashua River and the Merrimack River are fished extensively and wetlands are located along both rivers. Approximately 5,025 people receive drinking water from ground water wells within a 4-mile radius of the Site. However, a majority of the people living near the site are being supplied with potable water through the local water district.

The Site is comprised by two contiguous, approximately 15 acre parcels of land: a developed "northern parcel" that was historically used for tannery and waste disposal operations, and a "southern parcel" that is undeveloped and does not appear to have been used by the former tannery.

What Has Been Done to Clean Up the Site?

Public health and environmental concerns have been adressed in the past by a number of federal, state, and local actions. In 2000 EPA Region 1 proposed the Site to the National Priorities List (NPL). In September 2000 EPA removed and disposed of asbestos-containing material from the old tannery building; characterized and disposed of contamination contained in drums and tanks on site; and dispose of these at an off-site facility. This work finished in January 2001. Removing asbestos-containing material and drums/containers from the site reduced the potential for exposure to hazardous substances. Efforts by EPA (and the property owner) to further secure the Site have also reduced the potential for exposure to hazardous substances.﻿ To further secure the site, EPA repaired a number of gates and posted warning signs about the dangers of trespassing. The property owner maintains these gates and fences under a 2006 agreement with EPA and the New Hampshire Department of Environmental Services (NHDES).

In 2002, EPA proposed a non-time-critical removal action (NTCRA) for the site’s sludge disposal areas. EPA developed cleanup options for the six waste disposal areas at the site and also identified the Agency’s recommended cleanup approach for these areas. However, at the request of the City of Nashua, EPA did not move forward with the final NPL listing and the proposed NTCRA was put on hold. The City of Nashua believed there may be a viable developer that could possibly clean up the site, therefore requested that EPA not move forward with the NTCRA. As the Site has excellent redevelopment potential, EPA continues to coordinate with interested developers on options to advance the site cleanup and prepare the site for reuse.

As discussed below, EPA is now evaluating new approaches to the cleanup.

What Is the Current Site Status?

EPA recently completed an amendment to the 2002 EE/CA. The amendment re-evaluates alternatives considered in 2002 and other possible removal actions, and it recommends the on-site encapsulation and impermeable capping of the wastes as the preferred alternative. In addition to the removal actions at the Site, EPA’s EE/CA Amendment incorporates possible removal actions at two adjacent properties to the north of the Site: the Fimbel Door property and the City of Nashua’s Parkway Right of Way property. There is asbestos containing material (ACM) that is unrelated to the Site’s past activities on both properties; the Fimbel property includes a landfill that contains sludge waste from the Site’s operations. To facilitate a re-development proposal that is currently under review by EPA, NHDES, and the City of Nashua, the ACM at both properties and the sludge waste at the Fimbel Door Landfill needs to be addressed. Should the re-development proposal fail to be approved and/or implemented, EPA will consider other proposals, if available, or will proceed with listing of the Site on the NPL.

Sampling and Monitoring

Numerous environmental investigations and removal/pre-remedial activities have been completed at the Site in association with tannery-related wastes, and soil and groundwater contamination, from 1985 to the present. Please refer to the Administrative Record for a list of these investigations and how to obtain copies of them.

Green Remediation

The EE/CA Amendment screening process for all the cleanup alternatives considered short term and long term environmental impacts. The preferred alternative offers the best possible approach to minimize those.